R2 FACILITY NEWSLETTER I JULY 2022

FEATURE STORY:

NEW RESOURCES FOR YOUR R2v3     

INTERNAL AUDIT

If you are R2 Certified, you already know that internal audits are required in the R2 certification process. But did you know that there are significant enhancements to internal audit requirements in R2v3? Actually, there are three (3) internal audits required in R2v3: a legal compliance audit; a data security and sanitization audit; and an internal audit of the R2 standard. None of these internal audits are the same as your ISO 14001, 45001, 9001, or RIOS internal audits. Each internal audit requires an auditor who is competent in the subject matter, and is often not the same person. And where most certifications allow you to earn a Cert with some open minor nonconformances, R2v3 does not. It means that all nonconformances, including those from your internal audits, must also be closed prior to earning your R2 certification. That's because unlike management systems, R2 Certification is focused on outcomes, not just processes.

On the surface, internal audits can appear to be just another administrative formality. And some internal auditors do the bar minimum and check some boxes off a generic checklist. But when internal audits are done properly, they are a great way to find issues, increase efficiency, and prevent delays in your transition to R2v3. Your internal auditors should be digging deep enough to find any issues before your certification body auditor does. And since you will need time to correct those nonconformances before your transition audit, you should plan your internal audits weeks, if not months, before your transition audit. The more attention and effort you put into your internal audits, the smoother the rest of your v3 certification process should be. 

To help you along, SERI is continuing to develop resources around the Internal Audit function including our latest podcast, new soon-to-be-released training videos, and other IA tools that we’ll be adding to the R2 Knowledge Base in the coming weeks. And if you are looking for an in-depth discussion on the elements of an effective internal audit program, attend our session at the E-Scrap Conference on Tuesday, September 20th.

If you follow our R2 Certification LinkedIn account, you’ll learn about these resources as soon as we add them. And if you aren’t following us, what are you waiting for? 

CALL FOR EXPERTS:

DATA STORAGE AND SANITIZATION - JOIN THE WORKGROUP

To continue to work toward electronics sustainability, we want to reuse devices that still have good life left in them. But for that to happen, we need effective solutions for sanitizing the data that may be left on the electronics, outside of physical destruction. We know how to wipe hard drives, but not all devices that store data currently have recognized sanitization software solutions. Beyond sanitizing the data, we must also have a means for recording and maintaining the details of the sanitization and verifying the effectiveness of the process.  

Think about wearable electronics, smart home devices, and the growing connected internet of things. As the number of “smarter” devices rises and consumer adoption grows, this challenge will only increase. This is especially true when we are talking about processing devices at commercial volumes. 

SERI is convening a workgroup of volunteer experts to provide insight into this topic including manufacturers, software developers, and data experts. This is anticipated to be a light engagement, with no more than 3-6 calls over the next 6 months. The objectives for the workgroup will be to define the scope of the issue, including the types of devices affected; evaluate current options; and provide recommendations for alternative means of sanitization and verification where possible. 

If you are interested in volunteering, please apply by sending your contact info including current employer/organization and a brief summary of relevant data storage and sanitization experience to info@sustainableelectronics.org by August 15, 2022. Participants will be selected and notified by SERI thereafter. 

STATUS UPDATE:

R2v3: SOLAR 

It has been one year since SERI submitted the formal Project Initiation Notification with ANSI to kick-off the process for adding solar panels to the R2 Standard. Since that time, the R2 Technical Advisory Committee (TAC) established a workgroup to examine the applicability of the R2 requirements for solar panels and to begin writing new solar requirements. It is expected that the workgroup will have a draft of the requirements for the broader TAC review by the end of 2022. 

After the TAC reviews and considers each of the proposed changes and additions to the standard, the complete draft will be released for public review and comment. It is expected the 45-day public comment period will be held in the first quarter of 2023. And, as with any revision to the R2 Standard, all public comments received on the draft changes will be reviewed by the TAC and considered for additional possible changes. This public review process will continue until the TAC determines no further changes to the standard are required. 

You may be wondering what these changes will mean for the broader R2 Standard. Well, what’s important to remember is that the R2v3 Standard was restructured to include Core Requirements that are applicable to all R2 Facilities, and Process Requirements that apply only to those facilities that perform those operations. This structure is expected to enable the addition of specific solar panel requirements in a standalone appendix, without affecting the core of the R2 Standard. 

This means that if your facility does not manage solar panels, these changes won’t impact your R2 Certification or operations. 

However, for those that do manage solar panels, it is anticipated that it will be around the third quarter of 2023 that the final revision will be released, allowing facilities to begin certifying to R2 for solar panel reuse and recycling. Of course, existing R2 Facilities managing solar panels will require some time to review the new requirements and make changes to any processes and procedures. So, we anticipate there will be an 18-month transition period for R2 Certified facilities to add the solar panel processes to their active R2 certification. 

AVAILABLE R2v3 TRAINING CLASSES

NEW TO R2: INTRO TO R2 WEBINAR 

If you want to learn more about R2, join us on our Intro to R2 Webinars. They are held 3-4 times per month and are offered to accommodate time zones on all continents.

2022 LEAD AUDITOR TRAINING CLASSES

Looking for in-depth, online, and interactive training on R2v3? These classes are open to auditors, consultants, and facilities. Sign up for the class today!

In case you missed us:

• SERI's R2 Guru, Roger Greive, moderated a panel discussion on R2v3 Changes and How to Ensure Compliance at the ITAD Summit 2022 in South Florida on July 27th, 2022. 

Where we're going next:

• SERI's Executive Director, Corey Dehmey, will be speaking at the UN's 2022 E-Waste Academy - Scientist Edition (EWAS), sharing information with scientists in the industry August 27th - September 4th in Limerick, Ireland. 

• The SERI team will be attending the E-Scrap Conference in New Orleans, September 19th - 21st, 2022. Join us! 

• The SERI team will also be attending the E-Reuse Conference in Denver, CO on November 14th -16th.